Blog & Articles

Chief Counsel Advice 201603031 IRS has issued a Chief Counsel Advice (CCA) which notes that it hasn’t issued rules for calculating the penalty for intentionally failing to file information returns electronically. The CCA suggests internal IRS procedures for arriving at future IRS policy in this matter and sets out suggestions of how that calculation might […]

Allen, TC Memo 2016-13 In reviewing a determination by the IRS Appeals Office to proceed with collection of the taxpayers’ unpaid Federal income tax by levy, the Tax Court concluded that there were genuine questions of material fact to be decided at trial with regard to the taxpayers’ receipt of a notice of deficiency and […]

IRS has released three new International Practice Units (IPUs) providing guidance to its examiners on exchange of information (EOI) programs. “EOI” refers to the sharing of tax-related information between two or more countries for tax administration and enforcement purposes, generally under the provisions of U.S. income tax treaties and other international tax information sharing agreements. […]

NEW YORK (Reuters) – Two former Julius Baer bankers are expected to plead guilty on Thursday for helping wealthy American clients evade taxes as U.S. prosecutors unveil a $547 million settlement with the Swiss bank, a person familiar with the matter said. Daniela Casadei and Fabio Frazzetto, former client advisers at Julius Baer, are expected […]

OECD press release (Jan. 27, 2015). On January 27, finance ministers and top officials from 31 countries — which didn’t include the U.S. — signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the Agreement), according to an OECD press release. This is the first signing ceremony for the Agreement to facilitate […]

Notice 2016-10, 2016-6 IRB In a Notice, IRS has provided guidance with regard to regs it intends to issue on alternative methods that regulated investment companies (RICs) and their shareholders may use to satisfy their obligations under Code Sec. 853 and Code Sec. 905(c) where a RIC receives a refund of a foreign tax that […]

Family Chiropractic Sports Injury & Rehab Clinic, Inc., TC Memo 2016-10 The Tax Court has concluded that there was no abuse of discretion in IRS’s determination that an employee stock ownership plan (ESOP) was not qualified under Code Sec. 401(a) for its 2010 and subsequent plan years and that the related trust wasn’t exempt under […]

Form 8971, Information Regarding Beneficiaries Acquiring Property From a Decedent (January 2016). IRS has released the final version of new Form 8971, which, pursuant to legislation enacted in 2015, must be used to report the final estate tax value of property distributed or to be distributed from an estate, if the estate filed a Federal […]

NEW YORK (Reuters) – Uncle Sam is waiting for his cut from American taxpayers, including those who participate in the so-called sharing economy – doing side gigs like renting out their apartments, driving for Uber or running random errands for strangers on TaskRabbit.com. According to a recent data, Intuit Inc, the owner of the TurboTax […]

Chief Counsel Advice 201603025 In Chief Counsel Advice (CCA), IRS drew various conclusions regarding a taxpayer recognizing income form a nonqualified stock option that he received, including whether the underlying stock was readily tradable on an established securities market. Background. Under Code Sec. 409A(a)(1)(A), all amounts deferred under a nonqualified deferred compensation (NQDC) plan for all […]

As reported in the OC Register, Success does come with a price tag. Orange County’s economy begins 2016 on a six-year winning streak. But the extended upswing is creating challenges that may limit the local business climate’s advance. My Big Orange Index, a compilation of three dozen benchmarks of local economic performance, hit a new record […]

In postings to its website, IRS has noted that the current IRS forms for submitting certain employer plan user fees, including fees for employee plan determination letters, show fees that are no longer up to date, and has instructed taxpayers as to how to submit those fees. Background. The Employee Plans Compliance Resolution System (EPCRS) provides […]

SAN JUAN (Reuters) – Wal-Mart’s Puerto Rico subsidiary on Monday said a U.S. commonwealth tax on big companies is discriminatory, setting the stage for a trial starting on Tuesday that could threaten a tax increase Puerto Rico hoped would protect local businesses and jump-start its economy. In court papers filed ahead of the trial, in […]

Topsnik, 146 TC No. 1 The Tax Court has held that a taxpayer with connections to Germany, including a German passport, who had a U.S. green card for many years, was not a German resident, and was therefore subject to U.S. taxation as a nonresident. It also found that he was subject to the Code […]

As reported in the OC Register, Commercial real estate appraisals are required if you are financing a purchase through a lender – conventional or otherwise. The possible exception might be an owner-financed purchase. In that case, the owner becomes the bank and may not require an appraisal. An appraisal is a lender’s way of “hedging their […]

There will be no letup in the federal government’s ongoing campaign targeting U.S. taxpayers who hide foreign accounts and attempt to evade U.S. tax obligations, a key Justice Department (DOJ) official said on Jan. 29. In 2016, tax professionals will see “additional civil enforcement actions and ongoing and new criminal investigations and prosecutions,” Caroline Ciraolo, […]

BRUSSELS (Reuters) – Europe’s antitrust chief signalled on Monday her determination to go after Apple, Starbucks and McDonald’s over their tax deals in the bloc, dismissing U.S. criticism of her crackdown on the companies. European Competition Commissioner Margrethe Vestager’s comments come three days after senior U.S. Treasury official Robert Stack met her team in the […]

LG Kendrick, LLC, (2016) 146 TC No. 2 The Tax Court has held that it didn’t have jurisdiction to review the filing of a notice of Federal tax lien (NFTL) for a taxpayer for a certain period, concluding that, where the original notice of determination was insufficient to confer jurisdiction on the Court, a supplemental […]

SAN JUAN (Reuters) – Tax incentives aimed at spurring Puerto Rico’s economy have created 5,800 jobs in the four years since their enactment, but could create 50,000 more jobs in the next eight, a study commissioned by the island’s government said. The study, released on Tuesday by the economic consulting firm Estudios Tecnicos, said the […]

The Justice Department (DOJ) announced on Jan. 27 that it had reached its final non-prosecution agreement under the so-called Category 2 component of the Swiss Bank Program. HSZH Verwaltungs AG reached a resolution that requires the bank to pay a penalty of $49.8 million. Since last March, when the first non-prosecution agreement was made public, […]

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Law Offices of Paul W. Raymond

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The information on this website is for general information purposes only. Nothing on this or associated pages, documents, comments, answers, emails, or other communications should be taken as Tax Advice or Legal Advice for any individual tax issue or situation.